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reclamation bond, which P&M accomplished by submitting a rider to the "Life of Mine Bond"
<br />on July 5, 1988 that increased the bond from $20,000 to $70,520.
<br />On November 11, 1989, P&M submitted Bond Release Application SL-O1, requesting release of
<br />the $20,000 portion of the "Life of Mine Bond" being held for gully stabilization in the azeas
<br />subject to the 1983/1984 bond release request. On June 28, 1990, the Division approved this
<br />request, granting a release of $20,000. In July of 1990, P&M submitted a rider to the "Life of
<br />Mine Bond" reducing the amount from $70,520 to $50,520.
<br />On March 8, 1996, P&M submitted its application for Permit Renewal RN-03.
<br />On June 19, 1996, P&M submitted its application for Bond Release SL-02, requesting a Phase I
<br />bond release for reclamation work accomplished in the West Ridge and Center Ridge areas.
<br />On September 14, 1997, P&M submitted its application for Bond Release SL-03 for areas in East
<br />Ridge (Phase III) and Center Ridge (Phase II and III), and for the South of Shop Slide area (Phase
<br />I, II, and III). This application was subsequently withdrawn on November 9, 1997, and re-
<br />submitted on October 19, 1998 as Bond Release application SL-O5.
<br />On September 16, 1997, the Division proposed to approve P&M's application for Permit
<br />Renewal RN-03. The Division Findings Document states "The Division currently holds a
<br />$3,071,16 reclamation performance bond for the Edna Strip Mine. The current reclamation
<br />liability is $7,171,716. Reclamation liability for the disturbance in the West Ridge and Moffat
<br />Areas is $7,121,196. Remaining liability for the South of Shop slide area is $50,520. The South
<br />of Shop area was reincorporated into the pennit boundary in 1988, following a slope failure on
<br />previously lands in 1984." It is this $7,171,716 bond amount, composed ofthe $7,121,196
<br />"Permanent Program Bond" amount and the $50,520 "Life of Mine Bond" amount, that the self-
<br />bond application amount (approved in February 1998 for the amount of $7,171,716), and bond
<br />release amounts associated with Bond Release Applications SL-02, SL-04, SL-O5, SL-06, SL-07,
<br />SL-08, and this proposed bond release SL-09, aze based upon (see Appendix A).
<br />On September 18, 1997, Bond Release SL-02 was approved, reducing the bond required for
<br />remaining reclamation work from $7,171,716 to $6,350,103, a reduction of $821,613.
<br />Following the establishment of a reclamation liability of $7,171,716 during Permit Renewal 3,
<br />the September 18, 1997 approval of Bond Release SL-02, and the withdrawal of SL-03, five
<br />bond release applications have been approved.
<br />SL-04 was approved on October 26, 1998 for a Phase I Bond Release of $1,307,927 for
<br />reclamation work in the West Ridge (581.5 acres) and Center Ridge (15.6 acres) azeas of the
<br />permit. The bond required for remaining reclamation work was reduced to $5,042,176.
<br />SL-OS was approved on October 12, 1999 for a Phase II and Phase III Bond Release of $24,039
<br />for reclamation work in 53.1 acres located in Sections 13, 18, 19 and 24 T4N R86; and $50,520
<br />for Phase I, II and III reclamation work in 10.5 acres south of the shop. The bond required for
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